The proposed change does not recognize the critical care transport nursing specialty within the scope nursing practices. With a lack of a critical care interfacility regulation and the over simplification that a critical care transport nurse hold an EMS certification will only further complicate credentialing of the "employed provider" i.e. critical care transport nurse.

The Board of Nursing position statement should mimic the best practices that are authored by the accrediting nursing agencies / Air & Surface Transport Nurse Association (ASTNA) & Accreditation of Medical Transport Systems (CAMTS) which is the recognized specialty of advance scope of practice for critical transport nurses as "employed providers" when working for a health system that holds an EMS agency number .